LNG Canada Development Inc.

Transcription

1 LNG Canada Development Inc. Shell Centre 32 nd Floor th Avenue SW PO Box 100, Station M Calgary AB T2P 2H5 Canada Submitted electronically to: compliance.conformite@ceaa-acee.gc.ca April 20, 2016 Canadian Environmental Assessment Agency 22 nd Floor, Place Bell 160 Elgin Street, Ottawa ON K1A 0H3, Canada To Whom It May Concern, Re: LNG Canada Development Inc. ( LNG Canada ) Export Terminal Project, Decision Statement, Issued under Section 54 of the Canadian Environmental Assessment Act, Revised Implementation Schedule 11.3 to Decision Statement: The Proponent shall provide the Agency, or anyone designated pursuant to section 89 of the Canadian Environmental Assessment Act, 2012, with a revised implementation schedule if any change occurs from the initial schedule or any subsequent updates. The Proponent shall provide the revised implementation schedule at least 30 days prior to the implementation of the change. Therefore, please find enclosed the LNG Canada Revised Implementation Schedule. Updated information is related to marine work and is highlighted in yellow to facilitate review. We trust you will find the attached satisfactory. If you have any questions or concerns, please do not hesitate to contact the writer. Yours sincerely, Michael Lampp Environment Lead LNG Canada Development Inc.

2 LNG Canada Export Terminal Project: Implementation Schedule Prior to Construction 2.1 The Proponent shall, throughout all s of the Designated Project, ensure that its actions in meeting the conditions set out in this Decision Statement are informed by the best available information and knowledge, are based on validated methods and models, are undertaken by qualified individuals, and have applied the best available economically and technologically feasible strategies. 1-Aug-14 is understood and has applied to front end engineering design (FEED) and will continue to apply to all s of the Project The Proponent shall, where consultation is a requirement of a condition set out in this Decision Statement: 2.2.1: provide written notice of the opportunity for the party or parties to present their views on the subject of the consultation; 2.2.2: provide sufficient information and a reasonable period of time to permit the party or parties to prepare their views; 2.2.3: provide a full and impartial consideration of any views presented; and 2.2.4: advise the party or parties that have provided comments on how the views and information received have been considered. 17-Jun-15 is understood and relevant for duration of the project. LNG Canada has continued to consult with Aboriginal groups on conditions and related topics since the Decision Statement was issued by, based on established relationships and methods of communication : The Proponent shall, where consultation with Aboriginal groups is a requirement of a condition set out in this Decision Statement, and prior to the initiation of consultation, communicate with each Aboriginal group on the most appropriate manner in which to satisfy the consultation requirements referred to in condition Jun-15 LNG Canada has continued to consult with Aboriginal groups on conditions and related topics since the Decision Statement was issued by, based on established relationships and methods of communication. To confirm approach is still appropriate, LNG Canada sent letter to Aboriginal Groups on September 15, 2015 along with this Implementation Schedule. 2

3 : The Proponent shall, where a follow-up program is a requirement of a condition set out in this Decision Statement: 2.4.1: undertake monitoring and analysis to verify the accuracy of the environmental assessment as it pertains to the condition and/or to determine the effectiveness of any mitigation measure(s); 2.4.2: where the results of the monitoring and analysis indicate issues with respect to the accuracy of the environmental assessment or the effectiveness of any mitigation measures that may lead to adverse environmental effects, identify the means by which it will determine whether additional mitigation measures are required, including the need for consultation with other parties in reaching that determination; and 2.4.3: implement additional mitigation measures, as appropriate : The Proponent shall, from the reporting year where starts, submit to the Agency an annual report, including an executive summary of the annual report in both official languages. The annual report is to be submitted by the Proponent no later than June 30 following the reporting year. The Proponent shall document in the report: 2.5.1: implementation activities undertaken in the reporting year for each of the conditions; 2.5.2: how it has considered and incorporated the factors set out in condition 2.1 in the implementation of the conditions set out in this Decision Statement; 2.5.3: for conditions set out in this Decision Statement for which consultation is a requirement, how it has considered any views and information received during or as a result of the consultation; 2.5.4: the results of the follow-up program requirements identified in conditions 3.14, 4.2.4, 4.5, 5.3, and 7.2; and 2.5.5: any additional mitigation measures implemented or proposed to be implemented, as determined under condition Jun-15 1-Jan-16 LNG Canada has developed Environmental Management Plans (EMP) as required by EAO conditions. The EMP's outline the requirements for monitoring and implementation of mitigations stated or additional mitigations as required to manage environmental effects. The project monitoring programs will inherently verify the accuracy of the environmental assessment and describe the process for mitigating any additional effects identified during the monitoring of the various environmental aspects. is understood and is relevant for duration of project. The 2015 report will report activity from October - December

4 2.6 The Proponent shall publish on the Internet, or any similar medium, the annual report, the executive summary referred to in condition 2.5, the Wetland Compensation Plan referred to in condition 4.3, the plan to offset the loss of fish and fish habitat referred to in condition 3.11, the Archaeological and Heritage Resources Management Plan referred to in condition 8.1, the Decommissioning Plan referred to in condition 9.1, and the implementation schedule referred to in condition 11, following submission of these documents to the parties referenced in the respective conditions. The Proponent shall keep these documents publicly available for twenty-five years following the end of operation or until the end of decommissioning of the Designated Project, whichever comes first : The Proponent shall notify the Agency in writing no later than 60 days after the day on which there is a transfer of ownership, care, control or management of the Designated Project in whole or in part. As required 12 months prior to decommissioning activities commencing is understood and documents will be published on the LNG Canada website following submission of these documents to the parties referenced in the respective conditions. is understood and is relevant for duration of project : In the event that there is a transfer of ownership, care, control or management of the Designated Project from LNG Canada Development Inc. to another party, that party becomes the Proponent of the Designated Project and is bound by the conditions found in this Decision Statement. As required is understood and is relevant for duration of project 3.1 The Proponent shall implement erosion control measures and sediment control measures during all s of the Designated Project. is understood and is relevant for duration of project 3.2 The Proponent shall revegetate disturbed riparian areas, using native vegetation, as soon as practicable after. is understood and condition requirements are reflected in Vegetation Management Plan. 4

5 3.3 The Proponent shall isolate activities from adjacent freshwater fish habitat. is understood and condition requirements are reflected in the Fish Habitat Management Plan. 3.4 The Proponent shall salvage and relocate fish during in-water work requiring isolation of freshwater fish habitat. 3.5 The Proponent shall design the water intake for the Designated Project to avoid or reduce injury to and mortality of fish, including the risk of entrainment of eulachon larvae. The Proponent shall install the water intake that is so designed and shall monitor the operation of that intake to determine whether or not injury to and mortality of fish is avoided or reduced. Based on the monitoring results, the Proponent shall, as appropriate, modify the water intake or implement other measures to avoid or reduce injury to and mortality of fish. Jul-14 operational is understood and condition requirements are reflected in the Fish Habitat Management Plan. is understood and is relevant for duration of project 3.6 The Proponent shall apply low-noise methods or sound dampening technologies to reduce adverse effects to fish from exposure to underwater noise during pile installation. 01-Jan-17 is understood and will be implemented during marine. 5

6 3.7 The Proponent shall, prior to the start of in-water activities; establish the location and timing of sensitive life stages and habitat occupancy for fish (including marine mammals) in consultation with Fisheries and Oceans Canada and Aboriginal groups; advise the Agency of that information; and shall conduct in-water activities during the timing windows of least risk to those life stages and habitat occupancy, unless otherwise authorized by Fisheries and Oceans Canada. 3.8 When conducting in-water activities outside the timing windows of least risk referred to in condition 3.7, the Proponent shall implement additional mitigation measures following consultation with Fisheries and Oceans Canada, including sediment containment when dredging and using sediment disposal methods and equipment that will limit resuspension of sediments. LNG Canada has shared its Construction Environmental Management Plan with Aboriginal Groups, which contained information about timing windows for in-water. LNG Canada engaged in discussions with those First Nations that provided comments on the CEMP, and is committed to ongoing engagement should there be further questions or concerns. requirements are reflected in the Fish Habitat Management Plan and Marine Mammal Management Plan that was / is being developed in consultation with First Nations and DFO. is understood and is relevant for duration of of project 6

7 3.9 To avoid detrimental behavioural change in or injury to marine mammals, the Proponent shall establish and maintain a marine mammal exclusion zone for all activities where underwater noise levels are anticipated to exceed 160 decibels at a reference pressure of one micropascal. In doing so, the Proponent shall: 1-Jan-17 Marine is understood and is relevant for duration of marine works on project identify the activities that generate underwater noise levels greater than 160 decibels and the periods of time when those activities will occur; establish the boundary of the exclusion zone for each activity at the distance from the activity that the underwater noise level reaches 160 decibels; employ a marine mammal observer and specify the role of that person in observing and reporting marine mammals in the exclusion zone during activities identified in condition 3.9.1; specify the circumstances in which activities identified in condition must stop or not start if a marine mammal is sighted in the exclusion zone by the observer referred to in condition and not re-start until the marine mammal has moved out of the exclusion zone; and specify mitigation measures, such as sound dampening technology and soft-start procedures to reduce noise levels in the exclusion zone LNG carriers associated with the Designated Project shall respect speed profiles applicable to the operation of the Designated Project, subject to navigational safety, to prevent or reduce the risks of collisions between LNG carriers and marine mammals and shall report any collision with marine mammals to Fisheries and Oceans Canada, and notify Aboriginal groups. On or about 2021 On or about 2046 Only when the facility is operational will LNG carriers transit the proposed marine route. 7

8 3.11 The Proponent shall mitigate impacts to fish and fish habitat and, in consultation with Fisheries and Oceans Canada, develop and implement a plan to offset the loss of fish and fish habitat associated with the carrying out of the Designated Project For any fish habitat offsets area proposed in any offsetting plan under condition 3.11, and prior to submitting the offsetting plan to Fisheries and Oceans Canada, the Proponent shall determine whether there are adverse effects: on migratory birds and their habitats; on terrestrial species, including amphibians and reptiles, and their habitats; on species at risk and their habitat; on the current use of lands and resources for traditional purposes by Aboriginal peoples; on navigation; and from potential sources of contamination including polycyclic aromatic hydrocarbons, dioxins, furans, copper and zinc on the receiving environment. 25-Jun Started consultation with DFO in June 2014 and continue to work with on finalizing a fish and fish habitat compensation plan. Implementation and monitoring of constructed offset habitat to follow ( ). 5-Aug Aug-15 Document sent to Compliance.conformite@ceaaacee.gc.ca titled mem_fed_3_12_offsetting_effects_ The Proponent shall, if there are adverse effects on any of the elements of condition 3.12, avoid or lessen those adverse effects. 5-Aug-15 of offsetting habitat As noted in condition

9 3.14 In consultation with Fisheries and Oceans Canada and Aboriginal groups, the Proponent shall develop and implement a follow-up program to verify the accuracy of the environmental assessment and to determine the effectiveness of mitigation measures identified under conditions 3.1 to 3.11 and The Proponent shall participate in regional initiatives relating to cumulative effects monitoring and the management of marine shipping, should there be any such initiatives during the and operation s of the Designated Project. LNG Canada has shared various plans to address conditions 3.1 to 3.11 with Aboriginal Groups, as part of the EAO Working Group (included DFO) and through ongoing consultation. LNG Canada engaged in discussions with those First Nations that provided comments on plans received, and is committed to ongoing engagement should there be further questions or concerns. The EMP's outline the requirements for monitoring and implementation of mitigations stated or additional mitigations as required to manage environmental effects. The project monitoring programs will inherently verify the accuracy of the environmental assessment and describe the process for mitigating any additional effects identified during the monitoring of the various environmental aspects. is understood and is relevant for duration of project 9

10 4.1 The Proponent shall mitigate the adverse environmental effects of the Designated Project on wetland functions that support migratory birds, species at risk or the current use of lands and resources for traditional purposes by Aboriginal people. The Proponent shall give preference to avoiding the loss of wetlands over minimizing the adverse effects on wetlands and for managing the effects on wetlands over compensating for lost or adversely affected wetlands. is understood and is relevant for duration of of project 4.2 To avoid loss of wetlands or to manage adverse effects on wetlands impacted by the Designated Project footprint and adverse effects on wetland function on and for those wetlands adjacent to the Designated Project footprint, the Proponent shall: delineate clearing boundaries prior to the commencement of and respect those boundaries during ; maintain, where practicable, tidal flow and wildlife passage in the LNG loading line corridor between the LNG processing and storage site and the marine terminal; manage surface water and avoid erosion or sedimentation to maintain hydrology of adjacent wetlands and protect water quality; and conduct follow-up monitoring prior to and during to detect potential unanticipated loss of wetland functions and implement adjustments to mitigate loss of those wetland functions. is understood and is relevant for duration of of project 10

11 4.3 For effects on ecologically important wetlands that cannot be avoided or minimized, mitigation measures shall be set out in a Wetland Compensation Plan that shall be prepared by the Proponent in consultation with Aboriginal groups. The mitigation measures to be set out in the Wetland Compensation Plan shall include: implementing a 2:1 ratio of compensation area to the loss of ecologically important wetland area; identifying sites to compensate for the lost wetlands referred to in 4.3.1, that are as close to Kitimat as possible and that reflect similar wetland types and functions to those that are lost; a preference for wetland restoration over enhancement, and wetland enhancement over creation; and whenever possible, using traditional plants in the enhancement or creation of the compensation sites referred to in and providing access to those sites to Aboriginal people for the purposes of gathering traditional use plants. 4.4 The Proponent shall implement the wetland compensation plan within five years of the date of the start of. 4.5 The Proponent shall implement a follow-up program to verify that the compensation wetland sites are fulfilling the functions of the wetlands they are replacing and shall implement corrective actions in respect of the compensation wetlands if the latter do not fulfill those functions. The follow-up program shall include monitoring of the compensatory wetland sites to verify that lost habitat is being restored at or on those sites, in year one, and in years three, five, and ten following the enhancement or creation of the compensating wetlands. 27-Jul-15 Oct-15 LNG Canada's draft Wetland Compensation Plan was shared with Aboriginal Groups as part of the EAO's Working Group (included DFO). LNG Canada has engaged in discussions with those First Nations that provided comments on the plan, and is committed to ongoing engagement should there be further questions or concerns. The Wetland Compensation Plan will be submitted to EAO 30 days prior to commencing is understood. It is noted that monitoring is required post completion of offsetting habitat is understood. 11

12 5.1 The Proponent shall carry out all s of the Designated Project in a manner that protects and avoids harming, killing or disturbing migratory birds or destroying or taking their nests or eggs. In this regard, the Proponent shall take into account Environment Canada s Avoidance Guidelines. The Proponent s actions in applying the Avoidance Guidelines shall be in compliance with the Migratory Birds Convention Act, 1994 and with the Species at Risk Act. is understood and condition requirements are reflected in the Wildlife Management Plan. 5.2 The Proponent shall: 5.2.1: restrict flaring of vented emissions to the minimum required for maintenance activities or to manage emergencies; 5.2.2: minimize flaring during night time and during periods of bird vulnerability; and 5.2.3: adjust operational lighting to avoid attracting migratory birds operational is understood and is relevant for duration of project 5.3 The Proponent shall develop and implement a follow-up program to determine the effectiveness of the mitigation measures used to avoid harm to migratory birds, their eggs and nests during all s of the Designated Project. 4-Oct-15 is understood and condition requirements are reflected in the Wildlife Management Plan. 12

13 6.1 The Proponent shall incorporate noise and air emission reduction measures in the design of the Designated Project, and implement noise and air emission reduction measures during all s of the Designated Project to avoid or reduce potential effects on human health, including: complying with the Waste Discharge Regulation under British Columbia s Environmental Management Act for operational air emissions; applying best management practices and guidance for noise from the British Columbia Oil and Gas Commission s Noise Control Best Practices Guidelines; and complying with the operational noise requirement of the British Columbia Oil and Gas Commission s Liquefied Natural Gas Facility Regulation : :15-Oct : 2021 is understood requirements are reflected in the Construction Noise Management Plan. 6.2 The Proponent shall develop and implement a mechanism for receiving noise complaints, in consultation with Aboriginal groups and other parties who may be adversely affected by the noise caused by the Designated Project and during all s of the Designated Project, and respond in a timely manner to any noise complaint received. 17-Jun-15 LNG Canada has developed a Community Feedback and Grievance Procedure, and it is referenced in the draft Community Level Infrastructure Services Management Plan (CLISMP) which has been shared with Aboriginal Groups. A revised version will be shared in September with a request for specific feedback on procedure. 13

14 6.3 The Proponent shall implement measures related to marine water quality and sediment quality, including: 6.3.1: prior to the commencement of dredging, establishing a shellfish and groundfish tissue baseline and using it to complete a human health risk assessment for the consumption of fish; 6.3.2: conducting an assessment of the risks and potential duration of any exceedances of Canadian Council of Ministers of the Environment s Water Quality and Interim Sediment Quality Guidelines, and British Columbia s Water Quality Guidelines and Working Sediment Quality Guidelines that could occur during dredging and other in-water activities, and identify mitigation measures to avoid such exceedances; 6.3.3: implementing mitigation measures to minimize sediment dispersion during in-water activities, including isolation methods; 6.3.4: conducting onsite sediment and water quality monitoring in relation to the re-suspension and bioavailability of polycyclic aromatic hydrocarbons, dioxins and furans during in-water activities; 6.3.5: communicating any exceedances of the Canadian Council of Ministers of the Environment s Water Quality and Interim Sediment Quality Guidelines, and British Columbia s Water Quality Guidelines and Working Sediment Quality Guidelines to regulatory authorities in accordance with legislative requirements and to Aboriginal groups, and implementing mitigation measures identified in condition to remedy those exceedances or to reduce associated risks to human health; and 6.3.6: developing and implementing a post-dredging follow-up program, in consultation with Aboriginal groups, to confirm the human health risk assessment predictions, including additional sampling of the shellfish and groundfish tissue to confirm the assessment predictions regarding the bioavailability and bioaccumulation of contaminants in fish consumed by humans. The Proponent shall communicate the results of the follow-up program to Aboriginal groups May Mar Jan-17 Marine a baseline shellfish and ground shellfish tissue assessment was completed in May 2015, the results will inform a human health risk assessment to be completed prior to marine activities in Reported out on program Fall of 2014 with additional modeling being completed in March is understood and condition requirements are reflected in the Marine Water Quality Management and Monitoring Plan. 14

15 6.4 The Proponent shall, during operation, treat any effluent discharge from the facility marine outfall pipe to meet subsection 36(3) of the Fisheries Act and British Columbia s Water Quality Guidelines for the protection of marine life measured at the edge of the initial dilution zone : The Proponent shall develop and implement, in consultation with Aboriginal groups, a communication protocol for all s of the Designated Project. The communication protocol shall include procedures and practices for sharing information and facilitating communication between the Proponent and the Aboriginal groups and other local marine users on the following: 7.1.1: location and timing of Designated Project-related activities; 7.1.2: location and timing of traditional activities by Aboriginal groups; 7.1.3: safety procedures, such as navigation aids and updated navigational charts; 7.1.4: location of areas where navigation is restricted for safety reasons; 7.1.5: operational speed requirements under the Canada Shipping Act, 2001 or its regulations, and general schedules of the operation of LNG carriers associated with the Designated Project; and 7.1.6: ways in which to provide feedback to the Proponent on adverse effects related to navigation experienced by Aboriginal groups and other local marine users is understood and is relevant for duration of operational. 1-Jan-17 is understood and will be addressed as part of the Marine Activities Plan. 15

16 : The Proponent shall develop and implement, in consultation with Aboriginal groups, a follow-up program to verify the accuracy of the predictions made during the environmental assessment in relation to the effects of the wake generated by the Designated Project on the current use of lands and resources for traditional purposes by Aboriginal groups. The follow-up program shall include: 7.2.1: monitoring during the first two years of operation of the degree of wake generation by Designated Project-related vessels and of any adverse effects on harvesters caused by vessel wake attributable to Designated Project-related vessels at key harvest sites and during key harvest periods identified in consultation with Aboriginal groups; and 7.2.3: providing the results of the follow-up program and any corrective actions taken to Aboriginal groups. 7.3 The Proponent shall provide Aboriginal groups with the implementation schedule, updates or revisions to the implementation schedule pursuant to condition 11 at the same time these documents are provided to the Agency is understood and and will be addressed as part Wake Verification Plan for operations. 15-Sep-15 A copy of this Implementation Schedule was provided to Aboriginal Groups on September 15,

17 8.1 The Proponent shall, in consultation with Aboriginal groups and local historical societies, develop and implement an Archaeological and Heritage Resources Management Plan for the Designated Project prior to. The Archaeological and Heritage Resources Management Plan shall take into account British Columbia s Handbook for the Identification and Recording of Culturally Modified Trees. The Archaeological and Heritage Resources Management Plan shall include: a description of structures, sites or things of historical, archaeological, paleontological or architectural significance (including Culturally Modified Trees) that may be encountered by the Proponent during ; procedures and practices for on-site monitoring of activities that may affect a structure, site or thing of historical, archaeological, paleontological or architectural significance (including Culturally Modified Trees) and for the identification and removal of these resources; and a Chance Find Protocol if a previously unidentified structure, site or thing of historical, archaeological, paleontological or architectural significance (including Culturally Modified Trees) is discovered by the Proponent or brought to the attention of the Proponent by an Aboriginal group or another party during. 10-Jun-15 is understood. LNG Canada has consulted on the Construction Environmental Management Plan (CEMP) with Aboriginal Groups, which contains the Archaeological and Heritage Resources Management Plan. LNG Canada engaged in discussions with those First Nations that provided comments on the CEMP, and is committed to ongoing engagement should there be further questions or concerns. LNG Canada site induction will include relevant sections of the Archaeological and Heritage Resources Management Plan. 17

18 9.1 The Proponent shall develop and submit to the Agency a Decommissioning Plan at least one year prior to the end of operation, consistent with any statutory or regulatory requirements in effect at that time. The Decommissioning Plan shall include a description of: any consultation undertaken during the development of the Decommissioning Plan, including any issues raised by Aboriginal groups and other parties and how they were resolved by the Proponent; the components of the Designated Project that will be decommissioned by the Proponent; the desired end-state objectives of the areas that will be decommissioned by the Proponent and those that will not be decommissioned; the components of the environment that may be adversely affected by decommissioning activities or by components of the Designated Project that continue in their state at the end of operation; 10.1 The Proponent shall take all reasonable measures to prevent accidents and malfunctions that may result in adverse environmental effects and shall implement the emergency response procedures and contingencies developed in relation to the Designated Project is understood and will be addressed with a Decommissioning Plan is understood and is relevant for duration of project. 18

19 10.2 In the event of an accident or malfunction with the potential to cause adverse environmental effects, the Proponent shall: notify relevant federal and provincial authorities, including the Agency of the occurrence as soon as possible; implement measures to minimize any adverse environmental effects associated with the occurrence as soon as possible; submit a written report to the Agency as soon as possible in the circumstances, but at the latest 30 days after the day on which the accident or malfunction took place. The written report must include: the measures that were taken to mitigate the effects of the occurrence; a description of any residual environmental effects, and any additional measures required to address residual environmental effects; and if an emergency response plan was implemented, details concerning its implementation as soon as possible, but no later than 90 days after the day on which the accident or malfunction took place, submit a written report to the Agency on the changes made to avoid a subsequent occurrence of the accident or malfunction. As required is understood and requirements will be included in the site Emergency Response Plan for all s of the project The Proponent shall prepare and implement a communication strategy in consultation with Aboriginal groups that shall include: the types of accident or malfunction requiring a notification to the respective Aboriginal groups; the manner by which Aboriginal groups shall be notified of an accident or malfunction and of any opportunities to assist in the response; and points of contact for the Proponent and for the respective Aboriginal groups. is understood and requirements will be included in the site Emergency Response Plan for all s of the project. 19

20 11.1 The Proponent shall submit an implementation schedule for conditions contained in this Decision Statement to the Agency, or anyone designated pursuant to section 89 of the Canadian Environmental Assessment Act, 2012, at least 30 days prior to. The implementation schedule shall indicate the commencement and completion dates for each activity relating to conditions set out in this Decision Statement The Proponent shall submit an update to this implementation schedule in writing to the Agency, or anyone designated pursuant to section 89 of the Canadian Environmental Assessment Act, 2012, every two years on or before June 30, until completion of the activities The Proponent shall provide the Agency, or anyone designated pursuant to section 89 of the Canadian Environmental Assessment Act, 2012, with a revised implementation schedule if any change occurs from the initial schedule or any subsequent updates. The Proponent shall provide the revised implementation schedule at least 30 days prior to the implementation of the change. 15-Sep Sep-15 Letter sent on 15 September, 2015 to Compliance by Robert St. Jean - re: LNG Canada Development Inc. ( LNG Canada ) Export Terminal Project, Decision Statement, Issued under Section 54 of the Canadian Environmental Assessment Act, Implementation Schedule 2017 As required is understood and is relevant for duration of project Updated Implementation Schedule submitted 2016 Apr 20 20

21 The Proponent shall maintain a written record, or a record in an electronic format compatible with that used by the Agency, and retain and make available that record to the Agency, or anyone designated pursuant to section 89 of the Canadian Environmental Assessment Act, 2012, at a facility close to the Designated Project (local facility). The record shall include information related to the implementation of the conditions set out in this Decision Statement, and the results of all monitoring, including: the place, date and time of any sampling, as well as techniques, methods or procedures used; the dates and the analyses that were performed; the analytical techniques, methods or procedures used in the analyses; the names of the persons who collected and analyzed each sample and documentation of any professional certifications relevant to the work performed that they might possess; and the results of the analyses. 1-Aug-15 Use of Staketracker, SharePoint and Equis 21